Subject: Proposed Rule on 12-b(1) Fees and Net Asset Value Mutual Fund Sales

October 28, 2010

Dear Sirs:

I have been a licensed insurance representative for 35 years and a registered investment representative for 33 years. You can see my designations in my stationary. I am in favor of changing the 12b(1) Fees to 12b(2) Fees under the heading of "Marketing and Service" Fees. This will be much clearer to the consumer and let them discern whether they are getting the services that they are paying for.

In regard to the elimination of commissions in lieu of letting each brokerage house determine the net commission, this is a mistake. AI believe that this will result in a "price war" which will eventually eliminate investment services to the middle class. Each broker would be in a position to evaluate whether it is profitable to serve this market. Even if it would be initially profitable for newer brokers, they would try to work out of this market as soon as possible. We have already seen the result of this with some brokerage houses not paying commissions on clients who have less than $50,000 invested with the firm. How much attention will these clients continue to get from their broker? Many of these clients will not pay attention to the rapidly changing market conditions and investments will not match their changing objectives or risk profile.

I am committed to do what is best for my clients. I hope that you will consider this opinion.

Yours truly,

John A. Williamson, Jr. CLU, ChFC, AEP

John A. Williamson, Jr., CLU, ChFC, CLTC
Financial Representative